From: Jeremy Levine
To: Council, City
Cc: Burt, Patrick; Lauing, Ed; Veenker, Vicki; Lythcott-Haims, Julie; Lu, George; Reckdahl, Keith; Stone, Greer; Lait, Jonathan; Sauls, Garrett; Armer, Jennifer
Subject: Public Comment: Agenda Item 11, ADU ordinance; and Agenda Item 12, Rezoning 470 Olive Ave.
Date: Friday, September 4, 2026 3:19:24 PM
Attachments: 2026.9.9 Public Comment CITY COUNCIL Agenda Item 11 on ADUs; and Item 12 on Rezoning 470 Olive Street (1).pdf
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!
Good afternoon Palo Alto City Council members,
Please see the attached comment in support of rezoning 470 Olive Avenue, as proposed by staff. We also are requesting that council pull item 11, an update to the ADU ordinance, to make amendments to the "Main Home Penalty," which will arbitrarily punish homeowners who have built ADUs or plan to build them in the future.
Have a great weekend,
Jeremy
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September 9, 2026 Palo Alto City Council 250 Hamilton Avenue Palo Alto, CA 94301 RE: Agenda Item 11, ADU ordinance update ; and Agenda Item 12, Rezoning 470 Olive Avenue Dear Mayor Veenker, Vice Mayor Stone, and Members of the Palo Alto City Council, Palo Alto Forward supports policies to further housing affordability and multi-mobility accessibility
in
Palo
Alto.
To
that
end,
we
have
supported
ADUs
in
Palo
Alto
to
create
more
affordable
options
for
seniors
to
downsize,
children
to
move
home,
and
essential
workers
to
live
in
our
community.
In order to promote ADUs, please remove Item 11 from consent to amend footnote 7 of Table 1.
This
footnote
codifies
a
“Main
Home
Penalty”
in
Palo
Alto’s
ADU
ordinance,
which
would
punish
homeowners
who
have
built
an
ADU
or
plan
to
build
one
without
demolishing
their
primary
home.
We
agree
with
staff
that
the
ADU
ordinance
should
be
changed
to
add
clarity
around
square
footage
exemptions,
but
the
current
proposed
change
penalizes
homeowners
who
have
built
ADUs
and
does
not
reflect
recent
permitting
practices
for
ADUs.
To avoid penalizing homeowners who build an ADU, Palo Alto should amend Table 1 to include
the
same
Square
Footage
Exemption
as
Table
2 (see
below)
and
amend
footnote
7 of
Table
1 to
read:
“Square
footage
of
an
ADU
under
this
section
shall
not
reduce
the
allowable
square
footage
of
a
proposed
single-family
home
any
primary
dwelling.”
The Table 2 language we want inserted into Table 1: Square Footage Exemption when in conjunction with a single family home 1 Up to 800 sf
The context: ● As currently written, the ADU ordinance adds footnote 7 of Table 1, which reads “Square footage of a detached ADU under this section shall not reduce the allowable square footage
of
a
proposed
single-family
home.”
The
word
“proposed”
has
big
implications:
1 New text for footnote 7 of Table 1 in the ordinance: “Square footage of an ADU under this section shall
not
reduce
the
allowable
square
footage
of
any
primary
dwelling.”
1 ○ If a single-family home owner demolishes their home and rebuilds it at the max FAR
along
with
an
800
square
foot
Table
1 ADU,
that
ADU
is
exempt
from
the
FAR
under
local
zoning
rules.
○ If a single-family homeowner remains in their more modest home and builds an 800
square
foot
Table
1 ADU,
they
would
lose
800
square
feet
of
FAR
for
their
primary
home
under
local
zoning
rules
if
they
ever
want
to
expand
their
house
in
the
future.
● Staff argue that footnote 7—which was not present in the ordinance council reviewed on August
17—clarifies
longstanding
staff
practice.
However:
○ While a uniform square foot exemption has not been codified for Table 1, City Council
had
this
exact
discussion
in
2020.
Then,
the
staff
report
recommended
a
uniform
exemption.
2 ○ Operating under the assumption that there is uniform exemption, ADU builders have
been
submitting
applications
pursuant
to
Table
1 with
the
exemption.
Staff
has
been
processing
Table
1 ADUs
that
include
an
800
square
foot
exemption.
○ Furthermore, ADU permitting applications in Palo Alto do not distinguish between Table
1 and
Table
2 ADUs.
That
means
homeowners
who
have
built
an
ADU
don’t
actually
know
which
ADUs
are
Table
1 or
Table
2 ADUs—and
it’s
not
clear
staff
do
either.
The
August
17 staff
report
claims
staff
have
been
informally
counting
Table
1 ADUs
toward
FAR;
if
that
is
the
case,
homeowners
who
have
built
ADUs
using
Table
1 are
unaware.
ADUs have formed an essential part of the City's housing strategy, consistently resulting in the permitting
of
more
than
100
ADUs
annually—even
higher
than
the
64 ADUs
projected
in
Palo
Alto's
housing
element.
State
law
has
played
an
essential
role
complimenting
Palo
Alto’s
local
efforts.
Palo Alto can continue building on its ADU success by amending footnote 7 to give Table 1 and Table
2 ADUs
a
uniform
square
footage
exemption.
Otherwise,
the
City
risks
penalizing
modest
homeowners
who
built
an
ADU
or
plan
to
in
the
future
while
remaining
in
their
more
modest
homes.
The
Main
Home
Penalty
should
be
removed
entirely
so
that
Palo
Alto
continues
its
leadership
on
ADU
development.
Separately, we support the staff recommendation to rezone 470 Olive Avenue from the NV-R1
designation
to
the
NV-MXM
medium-density
designation.
We
also
support
staff’s
intent
to
add
this
site
to
the
Housing
Element.
2 City of Palo Alto City Council Staff Report (ID # 11118): The report discusses “Providing a Uniform Exemption
of
ADU
Square
Footage
from
FAR,
Lot
Coverage,
and
Maximum
House
Size,”
which
staff
recommended
because
“This
approach
could
make
it
easier
for
the
public
to
understand
how
these
limits
can
impact
what
is
allowed
and
make
it
easier
for
staff
to
implement.
It
also
would
remove
a
potential
incentive
to
demolish
an
existing
residence
to
max
out
FAR
before
building
an
ADU.
Finally,
this
approach
would
allow
a
property
owner
seeking
to
build
a
larger
ADU
to
do
so
if
there
is
additional
FAR
available
for
the
site.”
2 470 Olive Avenue already contains a defunct commercial business. The parcel is immediately next
to
the
El
Camino
Real
Focus
Area.
When
creating
the
ECR
Focus
Area,
council
directed
staff
to
independently
evaluate
whether
the
site
would
be
sufficient
for
new
multi-family
housing.
Having
conducted
their
evaluation,
staff
now
have
proposed
moving
forward
with
a
mixed-use
designation
better
reflecting
the
property’s
existing
use
and
redevelopment
potential.
Palo Alto’s local zoning should broadly allow development on existing corridors. Most new development
the
City
has
approved
in
recent
years
has
been
proposed
pursuant
to
state
laws
like
the
Builder’s
Remedy
that
circumvent
local
process;
470
Olive
reflects
an
opportunity
for
the
council
to
demonstrate
local
prerogative
for
new
homes
in
the
places
where
the
City
has
stated
it
wants
them.
The
structure
for
this
business
is
built
out
to
the
lot
limits
on
two
sides.
Replacing
this
with
housing
under
NV-MXM
zoning
would
give
more
separation,
via
setback
requirements,
to
those
two
residential
neighbors.
In an SB 79 local alternative plan, Palo Alto should encourage additional height and density on this
site.
For
now,
however,
the
staff
recommendation
will
best
indicate
the
city’s
intent
to
promote
more
homes
in
this
location.
Thank you for your consideration,
Jeremy Levine Executive Director, Palo Alto Forward 3 From: LAKIBA PITTMAN
To: Council, City
Subject: Item 12 – 470 Olive Avenue Rezoning: Please Consider the Cumulative Impact on Our Neighborhood Date: Saturday, September 5, 2026 6:41:37 PM
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Dear Mayor Veenker and Members of the Palo Alto City Council, I am writing regarding Item 12 on the September 9 agenda, the proposed rezoning of 470 Olive Avenue from Single-Family Residential (NV-R1) to Medium Density Mixed Use (NV- MXM).
I am a longtime resident of the neighborhood and recently appeared before the Council regarding the RV parking issue affecting Olive Avenue. I want to begin by thanking you for listening to residents' concerns and for voting to remove Olive Avenue, a residential street, from the proposed RV parking locations. I appreciated the Council’s responsiveness to our neighborhood.
I find myself writing again because residents in this small area are experiencing multiple, overlapping changes at once. Each issue may appear discrete when it comes before the Council, but for those of us who live here, their effects are cumulative. This proposed zoning change is therefore not an abstract planning question for those of us who live here. We have the large commercial properties along Page Mill Road and El Camino Real, the parking structure and development immediately behind our neighborhood, and additional housing development planned nearby along Park Boulevard and the El Camino corridor.
I understand Palo Alto’s need for additional housing, and I am not opposed to housing or thoughtful development. My concern is about the cumulative impact of continuing to increase density around one of the relatively small remaining pockets of single-family homes without adequately considering what that means for the people already living here.
Olive Avenue is a particularly small and unusual residential area. There are only a handful of homes on portions of the street, alongside existing commercial uses and major development nearby. Rezoning 470 Olive is therefore not simply a change affecting one parcel. It could change the character and future development trajectory of this small residential enclave.
I am especially concerned about traffic, parking, pedestrian and bicycle safety, emergency access, and the cumulative effects of projects already approved or underway in the immediate area. These impacts should be considered together rather than on a project-by-project basis, particularly given the significant changes that have occurred and continue to occur around El This message needs your attention
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Camino Real, Page Mill Road, Park Boulevard, Olive Avenue, and the surrounding Ventura neighborhood.
I also understand that the Planning and Transportation Commission did not reach a majority recommendation on this rezoning. That alone suggests the questions raised by this proposal deserve careful consideration before a permanent zoning change is made.
I respectfully ask the Council not to view 470 Olive Avenue in isolation. Please consider the cumulative development already affecting this small neighborhood, the experiences of the residents who live here, and whether sufficient analysis has been conducted on traffic, parking, safety, infrastructure, and the long-term consequences of extending mixed-use zoning further into the remaining residential portion of Olive Avenue.
Housing and neighborhood preservation do not have to be opposing values. Thoughtful planning should address Palo Alto’s housing needs while also recognizing when a small, established residential neighborhood is bearing a disproportionate share of surrounding development impacts.
I urge you to either decline the proposed rezoning at this time or postpone action until the cumulative impacts on the immediate neighborhood have been more fully evaluated.
Thank you for your consideration and for listening to those of us who live with the consequences of these decisions every day.
Sincerely,
Lakiba Pittman
Palo Alto resident
Olive Avenue neighborhood
From: Pepper Person
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki
Subject: 9/9/2026 City Council Meeting: [Item #12 / 470 Olive Zoning: The Record Does Not Justify NV-MXM] Date: Monday, September 7, 2026 9:48:53 AM
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Mayor Veenker, Vice Mayor Stone, and Councilmembers,
The proposed change of 470 Olive from NV-R1 to NV-MXM raises a critical question:
What changed since NVCAP, and since Council revisited this boundary in May 2025, that warrants changing 470 Olive from NV-R1 to NV-MXM?
The 2019 staff report makes the history exceptionally clear.
In 1978, Council changed 470 Olive from CS to R-1 to achieve consistency with the Comprehensive Plan, after which the commercial use became nonconforming.
In 1987, Council approved an exception subject to conditions; the prior owner did not implement them and in 1988 affirmatively declined to pursue the exception.
After years of coordinated planning, NVCAP designated Olive/Pepper as an “area of stability” that would not experience a significant degree of change. Under the resulting zoning, 2951 El Camino is NV-MXM while 470 Olive remains NV-R1.
Council revisited this boundary again in May 2025. It expanded the El Camino Focus Area to 2951 El Camino but left 470 Olive outside because of its zoning and concerns about impacts on adjacent residential properties.
Now Council is being asked to walk back years of planning and decades of decisions to create a jagged boundary.
The item before Council is framed in its title as “aligning” 470 Olive with the NV-MXM zoning of the adjacent and connected 2951 El Camino parcel.
Instead of aligning, it would arbitrarily create an out-of-place notch in the established boundary.
Rezoning 470 Olive would project MXM one parcel into the residential block. 471 Pepper would then face MXM on two sides; 456 Olive would newly abut MXM. NVCAP preserved This message needs your attention
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this long-standing edge rather than extending MXM farther into Olive.
Moreover, rezoning 470 Olive to MXM does not unlock multifamily housing. SB 79 already did that.
Under today's zoning, 470 Olive (5,983 square feet), provides ~10,500 square feet (1.75 FAR, NV-R1(TOD)) of allowable multifamily floor area at. MXM increases that to ~12,000 square feet (2.0 FAR).
The incremental base FAR is therefore ~1,500 square feet.
Critically, this proposal is not presenting a choice between housing and no housing.
PTC considered the request and split 3-3.
And yet, where is the housing application? There is none.
Instead, staff states that “potential development partners are waiting” and that rezoning first gives owners and investors greater certainty.
That is about investors' needs. No housing project is being approved here.
The entitlement value created by this vote is concrete. The claimed housing benefit remains undefined.
Finally, while No Net Loss creates a legitimate City obligation, it does not itself select 470 Olive. Staff attributes the moderate-income capacity shortfall to approvals at Geng Road and 3606 El Camino.
If this particular 5,983-square-foot parcel is needed to cure that citywide shortfall, the report should show the arithmetic and explain why moving this recently reaffirmed boundary is preferable to the available alternatives. It does not.
In short: this boundary has been repeatedly considered; rezoning 470 to MXM does not unlock multifamily housing; and there is no housing project here before Council. The record establishes neither the need nor the planning basis for MXM here.
We therefore urge Council to deny the NV-MXM rezoning and NVCAP amendment for 470 Olive.
Thank you for your consideration,
Jason Robinson, PhD, MBA
Jieming Robinson, MA, Economics
For the administrative record: We object to reliance on Public Resources Code § 21080.085 unless the record establishes that this specific NV-MXM rezoning implements the schedule of actions in the City's HCD-approved Housing Element, including Program 1.2(B). HCD's guidance states that a No Net Loss rezoning may qualify where the Housing Element contains a specific commitment and discrete timing, but the rezoning must implement that commitment. The record should therefore identify the remaining moderate-income capacity shortfall, the capacity attributed to 470 Olive under its existing NV-R1/TOD zoning and under proposed NV-MXM zoning, and why this particular rezoning is needed to maintain adequate sites.
We further object that the record does not establish that the Comprehensive Plan as amended would remain internally consistent under Government Code § 65300.5. NVCAP's retained land-use framework describes the Olive/Pepper low-density residential area as an “area of stability” that will not experience a significant degree of change. The record should reconcile the proposed one-parcel Medium-Density Mixed Use designation with that retained framework and with the adjoining NV-R1 area.
From: Matthew Bryant
To: Council, City; Kallas, Emily
Cc: Candy
Subject: Oppose a zoning map amendment for 470 Olive Avenue (Project 25PLN-00228) Date: Monday, September 7, 2026 8:15:21 PM
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Item 12 on the Palo Alto City Council Special Meeting agenda for Wednesday, September 9, 2026, is a public hearing regarding a zoning map amendment for 470 Olive Avenue (Project 25PLN-00228) Dear distinguished Mayor Veenker, Vice Mayor Stone, and City Councilmembers,
We are writing to you once again to oppose the 470 Olive Ave rezoning application from single-family home (NV-R1) to medium-density mixed use (NV-MXM).
<!--[if !supportLists]-->1) <!--[endif]-->The Palo Alto City Council already rejected a 470 Olive redevelopment proposal in January 2021.
<!--[if !supportLists]-->2) <!--[endif]-->Last month, the Palo Alto PTC split 3–3 on this upzoning application: Kevin, Allen, and Bryna opposed it; Forest, Bart, and Cari supported it; and Todd was absent. As a result, the PTC recommended that the City Council make the final decision. We believe Todd would have opposed the application had he attended, and that if Forest had acknowledged his misconduct and resigned sooner, this matter would not have come before the City Council in this way.
<!--[if !supportLists]-->3) <!--[endif]-->The North Ventura coordinated area plan (NVCAP) was approved by Palo Alto City Council in 2018 and ratified again in 2024. It should be respected and it shows on Page 31, “Respecting single-family homes” pointing to Olive and Pepper Ave.
Furthermore, Page 35 states “…being sensitive to the existing single-family neighborhood fabric -located along Pepper Avenue and Olive Avenue. This area of existing single-family homes has been designated as an area of stability and will not experience a significant degree of change.”
<!--[if !supportLists]-->4) <!--[endif]-->470 Olive Ave has not complied with Palo Alto Municipal Code, existing building codes, and property zoning for decades since 1978. There are two similar style brick buildings at 440 Olive and 440 Pepper, both of which have compliant, single- family home residence. The current owner(s) of 470 Olive has never lived there and reside in Half Moon Bay, nor have they put it on the market to sell 470 Olive as a single-family home so another family could reside in our neighborhood. They also incorrectly misstate their two property buildings as being connected. The truth is there are two separate buildings with a 6 feet difference between roof heights and if they are adjoined by an opening then it was done without a building permit. Once again, the city continues to allow this non-compliance without fines and penalties continues. Why are 470 Olive Ave owners given special treatment and zoning exemption with impunity?
<!--[if !supportLists]-->5) <!--[endif]-->470 Olive Ave intends to upzone to MXM, combine with 2951 El Camino Real (and likely 2999 El Camino Real) and sell for an estimated 10 million dollars to Summerhill Homes. Summerhill Homes recently reached out to Mark Johnson of Acclaim Properties and owner of 2905 El Camino Real to buy 2905 El Camino Real. He said the deal went cold after Summerhill would not pay the same price as 2951 El Camino Real. In summary, the 470 Olive/2951 El Camino Real owner and Summerhill corporation stand to make huge profits on this corporate real estate deal. The main issue here is the optics of a large corporation buying a single- family home and then upzoning it to commercial use. This is a bad look for Palo Alto.
<!--[if !supportLists]-->6) <!--[endif]-->There is a new single-family home currently being built at 460 Olive Ave (formerly known as 456 Olive Ave) next door to 470 Olive that includes a single-family home with ADU and junior ADU to make full use of providing additional housing within the R-1 building code. The 460 Olive owner clearly understands the single-family housing zoning and is following the building codes. This is a good neighbor.
<!--[if !supportLists]-->7) <!--[endif]-->Other single-family homes on Olive and Pepper Ave are adding ADU and junior ADU to provide additional residential housing within the R-1 single-family building code, including 461 Pepper Ave, 305 Olive Ave, and 295 Olive Ave to name a few.
<!--[if !supportLists]-->8) <!--[endif]-->The South Palo Alto and Ventura neighborhoods continue to take on the majority of the high- density housing projects with no signs of stopping new
developments. Currently within one block of 470 Olive, there are high density developments at Acacia St (Dividend Properties, 16 new condos), The Cannery (3200 Park, Fry’s, 74 townhomes), 3001 El Camino Real (Charity/Mike’s Bikes, 130 apartments), 3150 El Camino Real (Fish Market/McDonald’s/Acclaim Properties, 368 apartments), 3265 El Camino Real (Half Dome Capital, 55 apartments, 75% PAUSD teacher), and 3225 El Camino Real (8 new apartments). There continues to be a mapping inequality and neighborhood redlining in South Palo Alto when compared to North Palo Alto neighborhoods.
<!--[if !supportLists]-->9) <!--[endif]-->This jeopardizes the Olive and Pepper Ave single-family home residence district formerly known as the Sunnyside District of Mayfield (Olive and Pepper Ave, now part of Ventura District). Once the City Council allows one single-family home to upzone, then anyone else could be allowed to upzone.
<!--[if !supportLists]-->10) <!--[endif]-->Per the building code, allowing a R-1 with 1-2 story single family home to dramatically upzone to a medium- density mixed use with 5-6 stories of apartments is egregious and should not be allowed adjacent to existing single-family homes (as detailed in the spirit of the NVCAP).
<!--[if !supportLists]-->11) <!--[endif]-->471 Pepper Ave parcel will be mostly impacted by the upzoning as it will have two commercial use lots behind it and to the side of it. This unfairly and disproportionally devalues the single-family home residence.
<!--[if !supportLists]--> <!--[endif]-->
12) When Emily Kallas, project planner, was asked
about the privacy standards, she could not provide specific details of R-1 versus MXM. However, we know that a combined 470 Olive Ave/2951 El Camino Real higher-density mixed use property with bonus density could have far greater height allowance, with larger walls, balconies, and windows with direct line of sight into the adjacent single-family homes at 460 Olive Ave, 461 Pepper Ave, and 471 Pepper Ave.
<!--[if !supportLists]-->13) <!--[endif]-->We object to reliance on Public Resources Code § 21080.085 because the administrative record does not establish that the proposed rezoning implements a schedule of actions contained in a Housing Element that has been approved by the California Department of Housing and Community
Development (HCD), as required by Government Code §
65583(c).
In summary, we oppose the application to rezone 470 Olive Ave single family residence in a residential zone. Please urge the owner to comply with the Palo Alto Municipal Code and build a single-family home like the single-family homes that have been recently built around them. If they do not wish to comply with the single-family residential zoning, they should sell the property to another owner who will. We are asking the city to affirm the single-family residential zoning and the commitment the city made to honor and uphold the NVCAP and respect our neighborhood.
Respectfully,
Drs. Matt Bryant & Candy Tsourounis
471 Pepper Ave, Palo Alto